Last updated on July 16, 2018
Mycovia Pharmaceuticals, Inc. (“Mycovia”) respects your concerns about privacy. We want you to understand the types of information we collect, how we use that information, how we secure it, and whether we share it. When you use our website or participate in a clinical trial, either as a service provider, investigator, study coordinator, or data subject, you agree to our collection, use, disclosure, and transfer of information as described in this policy, so please review it carefully.
If you have executed a contract with Mycovia, or signed an informed consent document related to a Mycovia-sponsored clinical trial, where the provisions of such contract or consent conflict with the terms of this policy, the terms of the agreement or consent document shall control.
Information We Collect or Receive
We only collect, use, share, store, or otherwise process your personal information when we have an appropriate basis. For example, we may process your personal information as necessary to facilitate our business or in connection with your participation in a clinical trial. We may also process your personal information when necessary to comply with legal obligations, such as regulatory requirements, or for purposes of pursuing legitimate interests, if doing so is consistent with your rights and appropriate to the context, such as providing products, services or information you have requested, responding to your questions or concerns, and conducting reasonable monitoring of our website to prevent misuse and fraud. Additionally, we may, in certain cases, ask you for your consent for certain processing of your personal information, such as when you participate in a clinical trial as a data subject. In those cases, we may process your personal information for any purpose disclosed to you at the time you provided your consent for such processing.
We generally collect or receive information in three ways: (1) you voluntarily provide information to us; (2) we collect information automatically, such as through cookies in our website; and (3) other parties, such as agents of Mycovia, may provide information to us. Each of these methods is described in more detail below.
(1) Information You Provide
You may provide your personal information to us when you choose to use our website, or when you participate in a Mycovia-sponsored clinical trial. Because we change the offerings and features on our website from time to time, the options you have in order to provide us with information also may change. The information you provide to us through our website may include your name, title, your practice name (if applicable), your contact details such as physical address and/or mailing address, your email address, telephone number, and any additional information you choose to provide us in the message.
The following are some examples of situations in which you may provide information to us:
Participating in a Mycovia-sponsored clinical trial;
Completing a survey or questionnaire for Mycovia;
Entering information into the “contact” page of our website for general inquiries or to become an investigator;
Subscribing to Mycovia notifications or newsletters;
Contacting us for any reason, such as by email.
(2) Information Collected Automatically When You Use Our Website
When you access the Mycovia website, whether by computer, mobile phone, or other device, the website automatically collects information using technologies such as cookies. Automatically collected data may include, without limitation, information regarding your:
Geographical location and identification of your computer, mobile, or other device;
Bandwidth use and system and connection performance;
Operating system, browser type, and version numbers;
Length of visit and page views;
IP address or other unique identifier for your computer, mobile phone, or other device; and
Mobile carrier, if applicable.
(3) Information We Receive from Others
In some cases, other parties provide us with information about you, such as agents of Mycovia who organize and implement our clinical trials. These agents could include investigators, study coordinators, or service providers who carry out functions related to Mycovia-sponsored clinical trials. Mycovia will treat the information received from these agents in accordance with this policy. In no circumstances will we or our agents process sensitive personal information about you, such as information about your health, race, ethnicity, national origin, political opinion, religious or philosophical beliefs, trade union membership, genetic data, or information about your sexual orientation or sexual life without your consent.
How We Use Your Information
As a general matter, we use your information to provide the products, services, or information you request, or for any purpose to which you agree when you consent to participation in a Mycovia-sponsored clinical trial.
For individuals involved with clinical trials (including trial subjects, their spouses/partners, caregivers, and relatives; clinical investigators, the personnel, consultants, contractors, managers, and agents of investigative sites; research institutions), we may use your information for the following purposes:
To evaluate products under investigation;
To assure compliance with regulations and reporting to authorities;
To send or receive correspondence or communications with you;
To develop, deliver, and improve our products, services, and other offerings;
For internal administrative and compliance purposes such as auditing and data analysis.
When You Pursue or Enter a Business Relationship with Mycovia
When you share personal information in pursuit or in furtherance of a business relationship with Mycovia, whether through our website or otherwise (i.e. soliciting business, submitting a request to become an investigator, sending advertising correspondence or materials, or submitting a proposal) Mycovia may use your personal information for such purposes including, but not limited to:
To communicate with you, respond to your offers or requests, or provide you with updates and information;
To conduct evaluations of prospective agents, suppliers, or providers;
To obtain proposals, cost estimates, and to enter, track, and archive contracts;
To improve the quality of Mycovia business operations, products, or systems;
To enable agents to perform certain activities on Mycovia’s behalf; and
For internal administrative and compliance procedures, such as auditing and data analysis.
When you Visit our Website
When you visit or use our website for any purpose, we use the information collected automatically from our website to:
Administer the Mycovia website and diagnose problems with web servers;
Count website users, measure traffic, and analyze trends;
Investigate security incidents;
Improve content and the delivery and effectiveness of the Mycovia website for website users; and
Understand referral sources and the effectiveness of advertisement and directory listings.
How We Share Your Information
We may share your personal information with contractors, service providers, and other third parties that perform services on our behalf and under our instructions. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. All service providers shall be under a contractual obligation to adhere to applicable privacy laws.
We may also disclose information about you: (i) if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials, (ii) when we believe disclosure is necessary or appropriate to protect the physical safety and/or wellbeing of any individual, (iii) in the event of suspected or actual illegal activity, or (iv) to comply with legal and regulatory obligations, such as those related to clinical trials, taxation, litigation, audit, or investigation. We also reserve the right to transfer personal information in the event a material change to our business is proposed or occurs, like a purchase, merger, joint venture, or acquisition. In that event, we will endeavor to direct the use of personal information in a manner consistent with this policy.
We store personal information for as long as we reasonably need it to fulfill the purposes for which it was collected. We will retain and use personal information as necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.
We provide you with choices about whether to provide us with personal information and whether it is shared. For example, when you provide information to us through our website, we generally only ask you for personal information that is necessary to fulfill the purpose for which the information is requested. You can choose not to give us the personal information we request. However, in some cases, if you decide not to provide the personal information we request, we will not be able to respond to your request.
In addition, we are required to seek your consent before we use your personal information for any purpose incompatible with the purposes identified in this policy. You may withdraw your consent given pursuant to this section at any time by sending an email to email@example.com. Any withdrawal of consent is only effective on a going-forward basis and will not impact processing we undertook while relying on your consent.
Other examples of your choices include:
You can browse our website without providing any personal information. We may collect some limited information automatically, as described above.
You may change your browser settings or take other steps to block, manage, or delete cookies. In some cases, blocking or disabling cookies may cause our website not to work as intended and some features may not be available. Our site does not respond to “do not track” browser signals at this time.
How We Protect Personal Information
We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. Generally, if you participate in a clinical trial as a data subject, Mycovia only receives information about you that has been pseudonymized, or manipulated to replace information that identifies you with non-identifying information, and most identifying personal information is maintained at the clinical trial site and/or is processed on Mycovia’s behalf by its agents.
Transfers of Information
As part of our operations, we may transfer information about you to any jurisdiction where we do business. We will transfer your personal information for any of the purposes identified in this policy to our service providers that may be located outside of the jurisdiction where you are located. The laws in those jurisdictions may not provide the same level of data protection compared to the laws in your country. However, we will treat your personal information as subject to the protections described in this policy.
When we transfer personal information from the European Economic Area (“EEA”) or Switzerland to another party located outside the EEA or Switzerland, we will rely on a legal framework that provides appropriate safeguards, which could include the standard contractual clauses, binding corporate rules, the EU-U.S. Privacy Shield program, or another framework deemed adequate by the European Commission.
Additional Privacy Rights and Obligations (EEA and Switzerland)
This section sets out rights applicable only to the personal information of individuals located in the EEA or Switzerland, and our obligations regarding their personal information. Mycovia is committed to maintaining accurate, complete, and current records of personal information. If you are located in the EEA or Switzerland, under the European General Data Protection Regulation (“GDPR”), you may have the right to access and review your personal information, and to request that Mycovia amend, correct, or delete personal information that is inaccurate, incomplete, or outdated. To the extent consistent with applicable law, Mycovia will, on request, provide you with confirmation regarding whether Mycovia or any of its agents may be processing your personal information, and will take commercially reasonable steps to:
Verify your identity before granting access to or making any changes to your personal information;
Confirm that your personal information is being processed according to this policy; and/or
Correct, update, amend, delete or otherwise remove any personal information found to be inaccurate, incomplete, or processed in a manner non-compliant with this policy.
If you would like to request access to or correction of your personal information, please submit your request by sending an email to firstname.lastname@example.org. Please include your name, email address, and postal address in your request, and describe specifically the information that you would like to access or correct so that we may respond appropriately and promptly. Mycovia reserves the right to charge a reasonable fee to cover costs for providing copies of personal information requested under this section.
Although Mycovia will make a good faith effort to provide you with access to your personal information, there may be circumstances in which Mycovia is unable to provide access, including but not limited to:
where the personal information is subject to legal privilege;
where the provision of access would compromise the privacy or legitimate rights of others; or
where the burden or expense of providing access is disproportionate to the risks to your privacy.
If access is restricted, Mycovia will provide an explanation for restriction and contact information for further inquiry.
If you are located in the EEA or Switzerland then you have the right to restrict or object to our processing of your personal information. The right to restrict processing arises only in limited circumstances, for example, if you think we are processing inaccurate information. In addition, if we are required to restrict processing but the requirement is temporary, we may not be permanently obligated to adhere to your request. We will, however, let you know when the restriction is lifted. In cases where our basis for processing your information is the satisfaction of our legitimate interests, you may object to our processing. However, we will decline your request if our interest in continuing to process your information is sufficiently compelling to legally override your interest in the request, or our processing is necessary to establish, exercise, or defend a legal claim. To request a restriction or to object to processing, please submit your request by sending an email to email@example.com.
In cases where we process your personal information pursuant to your consent, you may contact us by email to firstname.lastname@example.org to request that your consent be withdrawn.
Individuals residing in the EEA or Switzerland or whose personal information is processed by Mycovia also have the right to obtain their personal information so they can transfer it to another party, or ask us to do so on their behalf, which we will do when technically feasible. This right is limited, and only arises when our processing of your information is automated and based on your consent or an agreement with us. To exercise this right, please submit your request by sending an email to email@example.com.
Individuals residing in the EEA or Switzerland may make additional inquiries to Mycovia’s data protection representative using the contact details below:
(for Mycovia Pharmaceuticals, Inc.)
Prague 15000 Czech Republic
VeraSafe Ireland Ltd.
(for Mycovia Pharmaceuticals, Inc.)
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P Ireland
Individuals residing in the EEA or Switzerland also have the right to lodge a complaint with a supervisory authority established in their country.
This policy may be updated periodically to reflect changes in our personal information practices or relevant laws. We will indicate at the top of this policy when this policy was last updated. Please review this policy every time you access or use our website to make sure that you have reviewed the most recent version.
How to Contact Us
Mycovia encourages individuals covered by this policy to raise questions, concerns or complaints by sending an email to Mycovia at firstname.lastname@example.org or, if you reside in the EEA or Switzerland, by using the contact details provided above.